On January 25, 2011, the SEC held an open meeting concerning reporting by investment advisers to private funds and certain commodity pool operators and commodity trading advisors on Form PF under the Dodd-Frank Act. Among the topics at this meeting were the requirement that SEC-registered investment advisers with at least $150 million in private fund assets under management periodically file a new reporting form (Form PF), and rules dividing investment advisers into two groups, large advisers and smaller advisers.[1]

Final Rules

"'Large private fund advisers' are:

Advisers with at least $1.5 billion in assets under management attributable to hedge funds.

Advisers with at least $2 billion in assets under management attributable to private equity funds. All other respondents are considered smaller private fund advisers."

Large private fund advisers must file Form PF within 60 days of the end of each fiscal quarter, and within 120 days of each fiscal year.

"Smaller private fund advisers must file Form PF only once a year within 120 days of the end of the fiscal year, and report only basic information regarding the private funds they advise. This includes limited information regarding size, leverage, investor types and concentration, liquidity, and fund performance. Smaller advisers managing hedge funds must also report information about fund strategy, counterparty credit risk, and use of trading and clearing mechanisms."